Butte semi-weekly miner. [volume] (Butte, Mont.) 1886-1890, 1887-06-04

to June II. 1881 at the Hotel Berwick,
Boston. That they then removed to Win
throp in the County Of Suffolk and Com.
monwealth of Massachusetts and lived
there as husband and wife till September
1881, That they then went to the house
of the father of said Walter p. Shepard in
Chester Park in said Boston n there
lived together as husband and vile tiltMay,
1883. That on January 81, 1882, q child
was born named Margaret, who 10 the only
issue of said marriage.
Fifth. THAT in Nav. 1888, the habits of
drinking Of said Walter p. Shepard had
become very gross, 30 that it was impossi-
BILE for the plaintiff to live with him; that
he i'll treated and abused her, and that Tor
those and other good reasons she went
temporarily to live with her step-mother,
at 1O3 Boylston street, in said Boston.
where she remained until the autumn OF
1886, since which time she has lived in said
Somerville. :,
Sixth, That after the plaintiff left her said
husband he promised repeatedly to reform
and asked her whether, in case ne did so
reform, she would return and live with
him, to which she assented.
Seventh, That subsequently the habits
of in~toxication of said Walter p. Shepard
became so bad that he was obliged to 60
and did 20 to the Washingtonian Home in
said Boston an institution for the reforma.
tion Of drunkards. April II, 1884 and
there remained till July 1884 when he
removed to a similar institution at
Northampton in the State of Massachu-
setts where he remained until September
2, 1884. That during the stay at the
Washingtonian Home, the plaintiff visited
him regularly and that she visited him at
said Northampton and remained there
several days and was at all times DESTROYS
and solicitous to aid in his reformation.
That on this visits said Walter P. Shepard
constantly expressed his hope that he
Sally s. Shepard to come back and live
with him in case he should reform and that
she invariably pronounced and was ready
to do so.
Eighth, That said Walter P. Shepard
left said Northampton September 2, 1884,
without notice to said Sally S. Shepard, and
has never since seen her or communicated
with her directly, or has he asked her in any
way to live with him, but has remained
out of the commonwealth with the inten-
ton, as said Sally s. Shepard believes, OF
abandoning and deserving her.
Ninth, That the child of said marriage
has remained temporarily in the care Of
the mother of said Walter P. Shepard, in
edlO DOSCVAs duu 10 " hNS ooiN o0AS
That said Walter P. Shepard has neve
provided for said child. or for the plaintiff,
and that the plaintiff desires and intends
to take said child into her own custody
and care.
Tenth, That said Sally S. Shepard has
constantly visited said child while she has
been living with her grandmother, and that
the mother of said Walter p. Shepard has
always known of the address and residence
of said Sally S. Shepard, and that the
plaintiff is informed and believes that said
Walter P. Shepard has been constantly in
correspondence with his mother, and has
been able, through her, to learn. if he did
not know already. as to the residence oil
said Sally s. Shepard at all times since
May, 1883.
Wherefore the plaintiff not waving her
objections to the jurisdiction of this court
and claiming that Walter P. Shepard can
not lawfully proceed to obtain a divorce
or the custody of said child elsewhere than
in the courts of the Commonwealth OF
Massachusetts, respectfully prays that the
decree of divorce heretofore granted by this
Honorable Court and the decree awarding
the custody of said child to said Walter P.
Shepard may be annulled and that the
plaintiff may be permitted to come in and
defend the action brought by said Walter
P. Shepard and to show to this Honorable
Court chat the complaint OF said Walter
P. Shepard should not be granted.
[Signed]. SALLY s. SHEPARD.